Peter Nias, barrister and Centre of Effective Dispute Resolution (CEDR) panel mediator of Pump Court Tax Chambers in the UK, considers whether the arbitration provisions in the OECD’s Multilateral Instrument (MLI) and Action 14 proposals offer the only option for dispute resolution for all parties.
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The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says
As we build up to another busy year for the World Tax rankings and ITR Awards, we give a rundown of some of the major firms and trends within the Brazil tax market
Krause will take the reins until President Trump’s pick Billy Long assumes the role; in other news, CohnReznick became the latest tax firm to receive private equity backing
Gilles Roth, speaking at the Luxembourg Transfer Pricing Association’s launch event, also said that his country is ‘carefully considering’ the implementation of amount B
The ruling in January was the first time the court had unanimously upheld a taxpayer's position in a case concerning TP, according to a lawyer who worked on the case